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The HC held that a notice issued under Section 153C is valid only for the assessment years corresponding to the incriminating material seized or obtained. Relying on binding precedent from the Supreme Court and subsequently followed by a Division Bench of the Delhi HC, the court reiterated that satisfaction for issuing such notice must pertain strictly to those assessment years for which the evidence was gathered. Consequently, issuance of notice for assessment years beyond those linked to the seized material is impermissible. The assessee's appeal was allowed, quashing the notice issued for assessment years not covered by the incriminating material.
The HC held that a notice issued under Section 153C is valid only for the assessment years corresponding to the incriminating material seized or obtained. Relying on binding precedent from the Supreme Court and subsequently followed by a Division Bench of the Delhi HC, the court reiterated that satisfaction for issuing such notice must pertain strictly to those assessment years for which the evidence was gathered. Consequently, issuance of notice for assessment years beyond those linked to the seized material is impermissible. The assessee's appeal was allowed, quashing the notice issued for assessment years not covered by the incriminating material.
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